https://www.taxtmi.com/caselaws?id=305978 The ITAT ruled in favor of the assessee on all issues. It held that receipts from software distribution are not royalty, Adobe India is not a dependent agent PE, no additional profits need to be attributed to the PE, Adobe Ireland does not have a fixed place PE in India, and interest under Section 234B should not be levied. The assessee's appeals were allowed, and the Revenue's appeals were dismissed. en-us Wed, 27 Jul 2022 00:00:00 +0530 Mon, 02 Jan 2023 21:14:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=305978 The ITAT ruled in favor of the assessee on all issues. It held that receipts from software distribution are not royalty, Adobe India is not a dependent agent PE, no additional profits need to be attributed to the PE, Adobe Ireland does not have a fixed place PE in India, and interest under Section 234B should not be levied. The assessee's appeals were allowed, and the Revenue's appeals were dismissed. Case-Laws Income Tax Wed, 27 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=305978